Washington v. Davis

Washington v. Davis, 426 U.S. 229 (1976), is a landmark decision of the United States Supreme Court.

Two Black applicants who failed the Washington, D.C. police department’s written personnel test challenged it as racially discriminatory because a disproportionate number of Black applicants failed. The test, which measured verbal ability, vocabulary, and reading comprehension, had not been shown to predict job performance. The applicants argued that its disparate racial impact violated the Equal Protection Clause.

Significance

Justice White’s 7-2 opinion held that a law or policy violates the Equal Protection Clause only if it is adopted with a racially discriminatory purpose — disparate impact alone is not enough. Official action is not unconstitutional ‘solely because it has a disproportionate racial impact.’ The Court distinguished constitutional equal protection claims from statutory Title VII discrimination claims, which do allow disparate impact challenges. The ‘discriminatory purpose’ requirement remains the standard for equal protection claims.

Category

US Federal Case Law